J. Richard (Dick) Harvey

Villanova University School of Law and Graduate Tax Program

Distinguished Professor of Practice

299 N. Spring Mill Road

Villanova, PA 19085

United States

  • Villanova University School of Law and Graduate Tax Program

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    • Tel: 610-519-4474
SCHOLARLY PAPERS

20

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Scholarly Papers (20)

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1.

Offshore Accounts: Insider’s Summary of FATCA and its Potential Future

Villanova Law Review, Vol. 57, No. 3, 2012, Villanova Law/Public Policy Research Paper No. 2011-24
Number of pages: 27 Posted: 08 Dec 2011 Last Revised: 01 Mar 2012
J. Richard (Dick) Harvey
Villanova University School of Law and Graduate Tax Program
Downloads 2,150 (12,551)

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FATCA, Offshore Accounts, Foreign Account Tax Compliance Act, Qualified Intermediary, and Voluntary Compliance Initiative

2.

FATCA - A Report from the Front Lines

Tax Notes, p. 713, August 6, 2012, Villanova Law/Public Policy Research Paper No. 2013-3001
Number of pages: 4 Posted: 02 Aug 2012 Last Revised: 17 Dec 2012
J. Richard (Dick) Harvey
Villanova University School of Law and Graduate Tax Program
Downloads 1,002 (39,592)

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International taxation, FATCA, Offshore accounts, Foreign Account Tax Compliance Act, anti-money laundering, anti-terrorist financing, and Swiss accounts

3.

Worldwide Taxation of U. S. Citizens Living Abroad: Impact of FATCA and Two Proposals

George Mason Journal of International Commercial Law, Forthcoming, Villanova Law/Public Policy Research Paper No. 2013-3057
Number of pages: 32 Posted: 30 Aug 2013 Last Revised: 07 Sep 2013
J. Richard (Dick) Harvey
Villanova University School of Law and Graduate Tax Program
Downloads 931 (43,849)

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US citizens abroad, expatriation, residence based taxation, FATCA, Internal Revenue Code sections 911 877A and 2801, worldwide taxation, estate tax, international tax planning

4.

Apple's International Tax Planning

Villanova Law/Public Policy Research Paper No. 2013-3061, Presentation to the Villanova School of Law Tax and Corporate Law Societies on Wednesday, October 26, 2013.
Number of pages: 34 Posted: 20 Oct 2013
J. Richard (Dick) Harvey
Villanova University School of Law and Graduate Tax Program
Downloads 782 (55,656)

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International tax planning, Apple, US Senate Permanent Subcommittee on Investigations, shifting income, base erosion, profit shifting, Subpart F, CFC look-through rule, contract manufacturing, tax gimmicks, effective tax rate

5.

Corporate Tax Aggressiveness - Recent History and Policy Options

National Tax Journal, Vol. 67, No. 4, 2014, Villanova Law/Public Policy Research Paper No. 2014-1018
Number of pages: 21 Posted: 16 Nov 2014 Last Revised: 17 Nov 2014
J. Richard (Dick) Harvey
Villanova University School of Law and Graduate Tax Program
Downloads 585 (80,799)

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corporate tax aggressiveness, transparency, Schedule UTP, penalties, IRS whistleblower program, income shifting

6.

Testimony of J. Richard (Dick) Harvey, Jr. Before the U.S. Senate Permanent Subcommittee on Investigations May 21, 2013

Villanova Law/Public Policy Research Paper No. 2013-3051
Number of pages: 27 Posted: 03 Jun 2013 Last Revised: 30 Aug 2013
J. Richard (Dick) Harvey
Villanova University School of Law and Graduate Tax Program
Downloads 492 (100,174)
Citation 3

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International tax planning, Apple, US Senate Permanent Subcommittee on Investigations, shifting income, base erosion, profit shifting, Subpart F, CFC look-through rule, contract manufacturing, tax gimmicks, effective tax rate

7.

Schedule UTP: An Insider's Summary of the Background, Key Concepts, and Major Issues

DePaul Business and Commercial Law Journal, Spring 2011, Villanova Law/Public Policy Research Paper No. 2011-2004
Number of pages: 40 Posted: 11 Mar 2011 Last Revised: 08 Aug 2012
J. Richard (Dick) Harvey
Villanova University School of Law and Graduate Tax Program
Downloads 480 (103,225)
Citation 1

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Schedule UTP, transparency, privilege and work product, IFRS, tax reserves, and NOL carryforwards

8.

Offshore Accounts: FATCA Background, Developments, and Key Issues

Villanova Law/Public Policy Research Paper No. 2014-1006
Number of pages: 18 Posted: 19 Mar 2014 Last Revised: 27 Mar 2014
J. Richard (Dick) Harvey
Villanova University School of Law and Graduate Tax Program
Downloads 435 (115,866)

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Offshore accounts, FATCA, OECD Common Reporting Standard, Tax evasion

9.

U.S. MNCs’ Offshore Operations: An Unbiased View

Tax Notes, January 2, 2012, Villanova Law/Public Policy Research Paper No. 2012-2001
Number of pages: 7 Posted: 23 Dec 2011 Last Revised: 10 Apr 2012
J. Richard (Dick) Harvey
Villanova University School of Law and Graduate Tax Program
Downloads 401 (127,402)

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International taxation, US MNCs, Subpart F, Worldwide Tax System, Territorial Tax System, Competitiveness, and Corporate Tax Reform

10.

Corporate Inversions - Background, Causes, and Policy Options

Villanova Law/Public Policy Research Paper No. 2014-1017
Number of pages: 34 Posted: 02 Nov 2014 Last Revised: 11 Nov 2014
J. Richard (Dick) Harvey
Villanova University School of Law and Graduate Tax Program
Downloads 374 (137,777)

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Inversions, Income Shifting, US Corporate Tax Rate, International Tax, Lock-Out Effect

11.

Schedule UTP: Views of a Former Tax Adviser and Administrator

Tax Notes, p. 1259, September 20, 2010, Villanova Law/Public Policy Research Paper No. 2010-16
Number of pages: 5 Posted: 20 Sep 2010
J. Richard (Dick) Harvey
Villanova University School of Law and Graduate Tax Program
Downloads 373 (138,184)

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Schedule UTP, Tax Gap, Tax Accrual Workpapers, and Work-Product Doctrine

12.

Apple Hearing: Observations from an Expert Witness

Tax Notes, pg. 1171, June 3, 2013, Villanova Law/Public Policy Research Paper No. 2013-3050
Number of pages: 5 Posted: 03 Jun 2013 Last Revised: 10 Jul 2013
J. Richard (Dick) Harvey
Villanova University School of Law and Graduate Tax Program
Downloads 330 (157,812)

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International tax planning, Apple, US Senate Permanent Subcommittee on investigations, shifting income, base erosion, profit shifting, Subpart F, CFC look-through rule, contract manufacturing, tax gimmicks, effective tax rate

13.

Schedule UTP Guidance – Initial Observations

Tax Notes, p. 115, October 4, 2010, Villanova Law/Public Policy Research Paper No. 2010-17
Number of pages: 6 Posted: 28 Sep 2010 Last Revised: 01 Mar 2012
J. Richard (Dick) Harvey
Villanova University School of Law and Graduate Tax Program
Downloads 277 (189,497)

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Schedule UTP, Tax Gap, Tax Accrual Workpapers, and Work-Product Doctrine

14.

FATCA and Schedule UTP: Are these Unilateral US Actions Doomed Unless Adopted by Other Countries?

Villanova University School of Law Paper No. 2012-2005
Number of pages: 27 Posted: 27 Mar 2012 Last Revised: 29 Mar 2012
J. Richard (Dick) Harvey
Villanova University School of Law and Graduate Tax Program
Downloads 264 (198,935)

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FATCA, Offshore Accounts, Foreign Account Tax Compliance Act, Qualified Intermediary, Voluntary Compliance Initiative, Schedule UTP, transparency, and international compliance

15.

Ninth Circuit Brief of Amici Curiae J. Richard Harvey, Leandra Lederman, Ruth Mason, Susan Morse, Stephen Shay and Bret Wells in Altera Corp. v. Commissioner, in Support of Respondent-Appellant Commissioner

Number of pages: 45 Posted: 08 Jul 2016 Last Revised: 02 Sep 2016
Susan C. Morse, J. Richard (Dick) Harvey, Leandra Lederman, Ruth Mason, Stephen E. Shay and Bret Wells
University of Texas at Austin - School of Law, Villanova University School of Law and Graduate Tax Program, Indiana University Maurer School of Law, University of Virginia School of Law, Boston College Law School and University of Houston Law Center
Downloads 226 (231,494)

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Cost-Sharing, Clear Reflection of Income, Comparability, Arm's Length Standard, Arbitrary, Capricious

16.

Schedule UTP - Why So Few Disclosures?

Tax Notes, April 1, 2013, Villanova Law/Public Policy Research Paper No. 2013-3014
Number of pages: 6 Posted: 28 Mar 2013 Last Revised: 26 Apr 2013
J. Richard (Dick) Harvey
Villanova University School of Law and Graduate Tax Program
Downloads 203 (255,850)

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Schedule UTP, Transparency, Corporate Disclosures, Corporate Tax Gap, FIN 48

17.

Should the States Piggyback on Federal Schedule UTP?

State Tax Notes, p. 327, 2011, Villanova Law/Public Policy Research Paper No. 2011-09
Number of pages: 6 Posted: 03 Aug 2011
J. Richard (Dick) Harvey
Villanova University School of Law and Graduate Tax Program
Downloads 118 (399,640)

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Schedule UTP, State Taxes, Tax Gap, Tax Accrual Workpapers, Work-Product Doctrine

18.

Schedule UTP – Two Major Issues

Tax Notes, p. 1559, March 28, 2011, Villanova Law/Public Policy Research Paper No. 2011-03
Number of pages: 7 Posted: 11 Mar 2011 Last Revised: 30 Mar 2011
J. Richard (Dick) Harvey
Villanova University School of Law and Graduate Tax Program
Downloads 102 (443,877)

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Schedule UTP, transparency, tax reserves, and NOL carryforwards

19.

Global Trends in Information Reporting and Canada's Approach

This paper is an edited transcript of a panel discussion presented on November 28, 2010 and appeared in Canadian Tax Foundation, 2010 Conference Report, Villanova Law/Public Policy Research Paper No. 2011-12
Number of pages: 25 Posted: 01 Sep 2011
J. Richard (Dick) Harvey
Villanova University School of Law and Graduate Tax Program
Downloads 73 (545,389)

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aggressive tax planning, Australia, disclosure, reporting, risk, United Kingdom, United States

20.

Should APB 23 Indefinite Reinvestment Be Repealed?

Tax Notes, Vol. 149, No. 1, 2015, Tax Notes Today, Vol. 192, No. 12, 2015, Villanova Law/Public Policy Research Paper No. 2015-1019
Number of pages: 4 Posted: 07 Mar 2016
J. Richard (Dick) Harvey
Villanova University School of Law and Graduate Tax Program
Downloads 61 (599,052)

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APB 23, Indefinite Reinvestment, Permanent Reinvestment, Territorial tax System, Inversions, Income Shifting, US Corporate Tax Rate, International Tax, and Lock-Out Effect